Earlier this year Finra asked for feedback on how well it was engaging with its stakeholders—essentially Finra’s own version of late New York City Mayor Ed Koch’s refrain, ‘How am I doin’?”

The answer: Finra has improved some processes but still needs many fixes, industry groups said in comment letters, which were due Monday.

The Financial Services Institute (FSI), which represents independent firms and has many individual rep members, is upset by how Finra promotes BrokerCheck. The tone of the BrokerCheck advertisements ends up “vilifying the industry” by focusing on how to avoid bad actors, the FSI said. Outreach should instead have more about “the value of advice and how investors can find a qualified financial advisor,” the trade group said.

The advisory committees Finra uses to gather industry expertise also came in for some pointed criticism.

The committee process “does not give member firms the ability to provide meaningful input,” the Securities Industry and Financial Markets Association (SIFMA) said, and Finra “provides very little transparency on the selection and composition of the various committees.”

In fact, “we often hear that committee members are ‘sworn to secrecy,’” SIFMA said.

The big Wall Street trade group wants Finra to schedule more meetings, explain how committee members are chosen and publicize their names, disclose agendas ahead of time and provide the recommendations that committees make to the Finra board, including the feedback from committees that was incorporated into proposed rules.

The FSI also noted “the lack of transparency” in the committee process, and specifically, the lack of individual registered representatives on committees. It suggested that Finra form a registered representative advisory committee.

“Advisors interact with investors every day and can provide valuable feedback as to what issues they encounter most often,” the FSI said.

Additionally, firms hit out at an old industry bugaboo—regulation by enforcement.

These are enforcement cases or exam findings that brokerage firms say are based on unofficial legal positions rather than actual rules and official guidance. SIFMA cited cases involving mutual fund share classes, customer credit limits, automated surveillance (which is not a Finra requirement), inbound wires and the fraudulent takeover of an account.

Finra “staff are often implementing a standard of perfection and strict adherence to informal guidance,” SIFMA complained.

Finra’s operational transparency could also use improvement, trade groups said.

“There is little transparency into the magnitude of regulatory and related fees collected by Finra and the amounts that Finra spends on regulatory activities,” SIFMA said.

SIFMA said Finra should review fees to make sure they align to actual costs and are equitably allocated.

Finra’s request for feedback is part of its FINRA360 initiative, a broad review of its operations spearheaded by Finra CEO Robert Cook.